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<h1>Non-liability of employer: instructing agent to commit a criminal act does not create indemnity obligation.</h1> An employer who employs another to perform a criminal act is not liable to indemnify the agent for consequences of that act, whether the promise to indemnify is express or implied. This principle prevents contractual indemnity for civil liabilities and costs that arise from an agent's commission of unlawful acts instructed by the employer, as shown in examples involving assault and defamatory publication.